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Mazza v. Commonwealth8/17/1993
ion, the Commonwealth thereby acknowledged that no probable cause existed to arrest him. We disagree. As discussed above, the police articulated facts supporting reasonable suspicion that appellant was the person they sought for leaving the scene of an accident without filing a report, and that it was appellant's action that produced in plain view the cocaine that gave them probable cause to arrest him. Notwithstanding that the police described their actions as an investigatory detention, not an arrest, we hold that the facts established that an arrest supported by probable cause occurred when the cocaine was discovered as a result of the Terry stop and appellant was placed in handcuffs. Accordingly, we do not agree that the provisions of Code § 19.2-81 were violated.
For the reasons stated, the judgments of the trial court are affirmed.
Affirmed.
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